Proposed Jury Instruction for Motive

NOTICE TO COUNSEL AND JUDGES: As provided in the Court's Order accepting the proposed jury instructions for a period of working review, the Court's provisional approval "is for the purpose of refining and testing the application and accuracy of the pattern instructions and does not ensure error-free trials, and their use does not carry a no-reversal guarantee. It is not intended that this provisional acceptance is a final approval of the content of any instruction and each judge may use or refuse any instruction as he or she sees fit[,]" according to law. (emphasis added).

    The Court instructs the jury that the failure of the State to discover and prove any motive for the commission of the crime is not evidence of the innocence of the accused. Motive constitutes no element of the crime itself.